MURRAY Vs. IMPERIAL CHEMICAL INDUSTRIES LTD.

JUDGEMENT

(1.) IMPERIAL Chemical Industries (hereinafter call 'I.C.I.') appealed to the Commissioners for the Special Purposes of the Income Tax Acts against the following assessments to income tax made under Case I of Schedule D in respect of its trade in fibres :

(2.) THE question for the commissioners determination on the appeal was whether certain sums received under provisions contained in agreements or heads of agreement entered into by I.C.I. with nine overseas concerns were sums falling to be included as trading receipts in computing the amount of the assessments or the loss.

(3.) THE relevant facts found by the commissioners were summarised in the judgment of Cross J. as follows :